Last Updated: March 2023
If you do not wish to provide us with your personal information or sensitive personal data or information, please do not use the Xflow Services.
“Personal information” shall mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information, is capable of identifying such person.
“Sensitive personal data or information” or “SPI” shall mean personal information, which consists of information relating to any to the following of an individual:
b. financial information such as bank account or credit card or debit card or other payment instrument details;
c. physical, physiological, and mental health condition;
d. sexual orientation;
e. medical records and history;
f. biometric information.
A. INFORMATION WE COLLECT AND RECEIVE
Personal Information Collected from You The data that we collect from you may contain SPI or personal Information. The personal information which we will collect, store, use, process, and transfer may include but is not restricted to: name, gender, date of birth, father’s name, address, email IDs, PAN, phone numbers and other contact information of your Associated Individuals. We may also collect bank account details and details of other payment instruments (such as debit card/credit card information) belonging to you and your business associates, in connection with Xflow Services, which may be treated as personal information or SPI under applicable laws in some cases.
We may also collect documents that may serve as proof of identity and address. We may extract any and all identifiers from these documents and use them for the Purposes mentioned below, in accordance with law. You are not required to provide your or any third party’s Aadhaar number for the use of our Xflow Services and the submission of your Aadhaar number is entirely voluntary.
You must ensure that you have obtained the necessary consents and/or adhered to any other applicable legal requirements when sharing any personal information or SPI of your Associated Individuals with us.
Other Information You Provide
Payment information: To enable our payment partners to accept and pay out money globally, and make global cross border payments, we will need to collect the financial information you provide for this purpose including your credit/debit card information, your bank account number, bank IFSC code etc. The information we collect would depend on the payment method that you use. We may pass this information on to our third-party payment services vendors and to our partners, or these entities may also directly collect this information from you.
Information from our partners: Our banks, licensed service providers or other financial institutions that we have tied up with, and/or third party vendors (such as identity verification agencies) may pass some of your information to us. We may also collect this information ourselves and pass some of this information on to them for processing.
Technical information: We may directly or through our third-party vendors collect your device IP address, browser configuration details, the date and time of access and use of Xflow Services, and analytics information about how you are accessing and using Xflow Services. We collect information that your browser or device sends whenever you visit or use Xflow Services. We may also collect technical information such as browser and network details for the purpose of identifying signals of fraud.
Third party data: We may also receive information relating to you from third parties that we use to make our own information better or more useful. This might be aggregate level information or it might be more specific information.
- Review/ Opt-out
You have the right, upon request, to access and review the personal information provided by you. Upon discovering that the information provided is inaccurate or deficient in any manner, you may request us to make suitable changes or amendments to such information.
You have the option to refrain from disclosing your SPI to us. You will also have the option of withdrawing consent previously provided. However, exercising this option will impact our ability to provide you with any or all of the features and services of the Xflow Services.
B. PURPOSE OF COLLECTION
We may process information including SPI concerning you for the purposes mentioned below (the purposes above and contained below together Purposes).
To provide Xflow Services: Xflow will access and use your data as reasonably necessary and in accordance with your instructions to (a) provide, Xflow Services, including for the purpose of enabling cross-border payments on your behalf, for undertaking KYC/KYB verification in relation to your business, (b) prevent or address service, security, technical issues, or at your request in connection with support matters; (c) act in a manner required by law, (d) act in the manner expressly permitted in writing by you, and (d) offer you services incidental and ancillary to the provision of Xflow Services.
To improve our Xflow Services: We carry out research and analyze trends to better understand how Xflow Services are being utilized and to expand and improve them. We may use your information to make the Xflow Services serve you better.
To communicate with you:
Responding to your requests: If you contact us with a problem or question, we will use your information to respond.
Billing and account management: We use account data to administer accounts and keep track of billing and payments. We may use your account related information and other information available to us to process defaults.
Investigating and preventing misuse: We work hard to keep the Xflow Services secure and to prevent abuse and fraud and we may use any information from you for this purpose.
As required by law: We use information collected from you to comply with, as well as to enable our banks, payment service providers and other financial institutions to comply with obligations under law.
The information we collect is retained in our servers, for such periods as required for providing the Xflow Services in accordance with our data retention policy.
We will not retain any SPI for longer than is required for the Purpose for which such data or information was collected, or may lawfully be used, or is otherwise required under any other law for the time being in force.
D. SHARING AND DISCLOSURE
We may also disclose personal information with our employees, officers, agents, consultants, business associates, contractors, attorneys, etc., on a need to know basis for the Purposes.
We may also disclose and transfer your information to bona fide proposed investors from time to time.
Xflow will disclose any personal information if there is a legal requirement or if it is ordered to do so by a court of competent jurisdiction or to any government agency if required by law for the purposes of verification of identity, or for prevention, detection, or investigation of crime (including cyber incidents), or for prosecution or punishment of offences.
Xflow ensures the confidentiality and security of the personal information provided by you by implementing comprehensive information security practices and standards.
F. GRIEVANCE OFFICER